Opinion
21812-22
11-09-2023
KRISHAN K. GOSSAIN & KAVITA GOSSAIN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Richard T. Morrison, Judge
On November 6, 2023, the Court received from petitioner Krishan Gossain a document entitled "Documents, Witness List, Duration Requirements." Because the document contains some of the required elements of a Pretrial Memorandum, it will be filed as Petitioners' Pretrial Memorandum. The document contains a description of documents that petitioners intend to use at trial. Petitioners are reminded that on or before November 13, 2023 (i.e., 14 days before trial) they are required to exchange with respondent all unstipulated documents they intend to use at trial. Merely describing the documents in the Pretrial Memorandum does not satisfy this requirement. Petitioners are further reminded that on or before November 20, 2023 (i.e., 7 days before trial) they are required to file with the Court all unstipulated documents they intend to use at trial. Merely describing the documents in the Pretrial Memorandum does not satisfy this requirement.
Given the foregoing, it is
ORDERED that petitioners' "Documents, Witness List, Duration Requirements", received on November 6, 2023, is recharacterized as petitioners' Pretrial Memorandum.